Parks v. United States

Whether a new trial is warranted where the District Court failed to instruct the jury that, in order to convict a person under 18 U.S.C. § 922(g)(3), it must find that the Government proved beyond a reasonable doubt that he knew he possessed a firearm and “knew he had the relevant status when he possessed it.” Rehaif v. United States, 139 S. Ct. 2191 (June 21, 2019).

Petitioner was convicted under 18 U.S.C. §§ 922(g) and 924, which prohibit “knowingly possessing a firearm after having been convicted of a crime punishable by a term of imprisonment exceeding one year.” Petitioner was sentenced to twenty-four months following the revocation of his supervised release, and he was additionally charged under §§ 922(g) and 924 for the same firearm possession. Petitioner filed a motion to dismiss the indictment, arguing double jeopardy. The district court denied the motion, citing Johnson v. United States, 529 U.S. 694 (2000), and United States v. Woodrup, 86 F.3d 359 (4th Cir. 1996). Petitioner appealed his conviction to the Fourth Circuit, which held that Woodrup precluded Petitioner’s double jeopardy argument. The Supreme Court previously ruled in Rehaif v. United States, 139 S. Ct. 2191 (June 21, 2019), that the state must prove defendants knew both (1) that they were in possession of a firearm and (2) that they held the relevant status at the time of possession. Petitioner asks the Court to reverse the Fourth Circuit because it erred by not applying Rehaif as the controlling precedent. The Court granted certiorari and issued an order to vacate the judgment and remand to the Court of Appeals for the Fourth Circuit for further consideration in light of Rehaif v. United States, 588 U. S. ___ (2019). VACATED and REMANDED.